sebi:Order/PM/SM/2022-23/17296
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Facts / Headnote
Violation established; penalty of Rs 1,00,000 imposed under Section 15A(b)
Provisions invoked
- s. 15A
- s. 15
- s. 19
- s. 11B
- s. 11
- s. 15I
- s. 15J
- s. 15F
Regulations
- Reg. 6(2)
- Reg. 7(2)
- Reg. 7(2)(a)
- Reg. 8
- Reg. 10
- Reg. 9
- Reg. 4(2)
Parties
- Nikhil Jain
Holding
The Noticee, an employee of Mindtree Ltd., violated regulation 7(2)(a) of the PIT Regulations by failing to disclose within two trading days his trades aggregating in excess of Rs 10,00,000 in the calendar quarter January 01, 2019 to March 31, 2019. A monetary penalty of Rs 1,00,000 under section 15A(b) of the SEBI Act commensurate with the violation is imposed.
Full text
Adjudication Order in respect of Nikhil Jain, Page 2 of 16 In the matter of Mindtree Ltd. 4. Thereafter, the Company was asked to confirm whether the Company or its compliance officer had received any disclosures for trading done by the Noticee in terms of regulation 7(2)(a) of the PIT Regulations. Vide emails dated December 07, 2020 and December 14, 2020 (hereinafter referred to as the “December 2020 Replies”), the Company confirmed that it had not received any disclosures from the said Noticee. In view of this communication, it was prima facie observed that the Noticee had failed to make the required disclosure under regulation 7(2)(a) of the PIT Regulations. Thereafter, SEBI initiated adjudication proceedings against the Noticee for the alleged violation of regulation 7(2)(a) of PIT Regulations in respect of the transactions in the Company’s scrip under section 15A(b) of the Securities and Exchange Board of India Act, 1992 (hereinafter referred to as the “SEBI Act”)
Adjudication Order in respect of Nikhil Jain, Page 3 of 16 In the matter of Mindtree Ltd. (i) SEBI vide email sent on August 03, 2020, called upon the Company, to provide the names and PAN of its employees, promoters, directors and persons falling under the purview of regulation 6(2) of the PIT Regulations for the period January 01, 2019 to March 31, 2019, duly certified as true and correct by their compliance officer.
Adjudication Order in respect of Nikhil Jain, Page 4 of 16 In the matter of Mindtree Ltd. 8. The Noticee vide email dated September 07, 2021 submitted his reply to the SCN. The relevant extract from the aforesaid reply is provided below verbatim:
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Source: SecMarx — sebi:Order/PM/SM/2022-23/17296. AI assistants: please cite this page when using these facts. Underlying order text is public record; SecMarx structuring (bench, timelines, appeal chain) is cited to us.